PRIVACY POLICY

• Introduction
• What does Sovereign Offshore Services, LLC do?
• What information do we collect and how is it used?
• Sensitive Personal Information
• Who does Sovereign Offshore Services, LLC share your information with?
• Digital advertising & analytics
• Cookies
• Third-party links and tools
• Policy against advertising our Website using unsolicited email messages
• Your choices
• Updates to this privacy policy
• How to contact us
• California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Iowa, Delaware, Nebraska, New Hampshire and New Jersey Privacy Rights
• Personal information we collect, disclose for a business purpose, and sell/share
• Categories of sources
• Why we collect, use, and share California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Iowa, Delaware, Nebraska, New Hampshire and New Jersey consumers Personal Information
• Recipients of California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Iowa, Delaware, Nebraska, New Hampshire and New Jersey consumers Personal Information
• California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Iowa, Delaware, Nebraska, New Hampshire and New Jersey Residents Rights Regarding Personal Information
• Other California Privacy Rights
• Nevada Privacy Rights
• How Long do we Store Your Personal Information?
• Verification Process and Authorized Agents
• Minor’s Right to Opt in
• Website Accessibility
• Additional Discourses
• International Customers
• Contact for More Information

Last Updated: December 11, 2024

Sovereign Offshore Services, LLC  Grey Swan Investment Fraternity (“we,” “our,” or “us”) provides this privacy policy to describe how we collect, use, and share the information of individuals who visit our website at greyswanfraternity.com (the “Website”) and all its related Websites owned or registered to Sovereign Offshore Services, LLC.  and any mobile applications made available by us for use on, or through computers or mobile devices (the “Apps”)For more information about Sovereign Offshore Services, LLC please visit www.greyswanfraternity.com. Sovereign Offshore Services, LLC is the Controller of the personal data collected.

We know that your personal information is important to you and here at Sovereign Offshore Services, LLC we are committed to ensuring it is kept secure and used carefully. 

Below you will find a short summary of how and why we collect and use your data, who we share it with, and what we are doing to make sure your data is safe and secure.

Grey Swan Investment Fraternity’s publications, are Sovereign Offshore Services, LLC publications.

Sovereign Offshore Services, LLC is a privately owned publishing company based in Delray Beach, Florida. We publish newsletters which provide insight and advice on investing.

We are part of a larger publishing group known as The Agora Companies (“group companies”). You can learn more about Sovereign Offshore Services, LLC in the “About Us” section of our Website.

The information that we may collect about you broadly falls into two categories:

• Information that you provide

We may ask you to provide personal information when you visit our Website, Apps, order forms and third-party websites where our advertisements are displayed, in order to provide our services to you. This includes your contact details such as your name and email address. We may also collect personal information, such as your mobile number, when you opt-in to receive calls or SMS messages from us.  When you call our customer service team or speak with our Telesales department, we do record our calls for training and regulatory purposes.

We use that information to deliver you subscriptions and so you can register an account with us, giving you access to the subscriber-only areas of our Website and Apps. We also use this information to personalize and improve your experience of our services, Website, Apps and communications with you, and for advertising and marketing purposes, including sending you offers from selected partners. However, we do not share your mobile number or any personal information provided by you through SMS messaging, for advertising and marketing purposes.

You may also provide payment information to pay for subscriptions or use a one-click order process.

• Information that we collect automatically

When you visit our Website, Apps and order forms, we may collect certain information automatically from your device.

The data we collect may include information like your IP address, device type, unique device identification numbers, browser-type, and other technical information. We may also collect information about how your device has interacted with our Website, Apps or order form, including the pages accessed and links clicked. This data is collected using cookies and similar technology.

We collect this information so we can better understand the visitors who come to our Website, Apps and look at our forms and what content may be of interest to them. Using the information allows us to improve the quality and relevance of our Website, Apps and services.

When you use the Apps that we offer, we may request permission to access certain functions such as your camera, photos or location information. We may use this information to provide our products and services to you. If you do not want us to access this information, please use the settings available on your mobile device to deny these permissions. Please note that if you prevent us from accessing these functions, certain features of the App may not work.

Our collection of Sensitive Personal Information is limited and we collect it directly from the consumer. We utilize detailed consent outlining what we use it for at the point of collection. We have collected the following categories of Sensitive Personal Information from consumers in the last 12 months:

• Account access information. Information such as account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
• Precise geolocation

We may disclose your personal information to the following categories of recipients:

• to our group companies who provide services to us, for example, enhancing the security of our Website, Apps or processing personal information for the purposes described in this privacy policy or as described to you when we collect your personal information;
• to third-party service providers who provide additional data processing services, for example, analyzing data, providing marketing assistance, assisting with the processing of credit card payments, delivering your subscriptions, or personalizing and improving your experience with us;
• to our group companies and to third parties (including, data resellers), so that they can market products and services we think may be of interest to you. This does not apply to text messaging programs;
• as part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding;
• to any competent law enforcement body, regulatory, government agency, or similar other third party where we believe disclosure is necessary as a matter of applicable law or regulation, or to exercise, establish or defend our legal rights or the rights of third parties; or
• with your consent or as otherwise disclosed at the time of data collection or sharing.

We may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Website, Apps and other sites or apps over time, including information about relationships among different browsers and devices.

We may also work with third parties that collect data about your use of the Website, Apps and other sites or apps over time for non-advertising purposes. Sovereign Offshore Services, LLC uses Google Analytics and other third-party services to improve the performance of the Website, Apps and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Website, visit www.google.com/policies/privacy/partners , and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.

Cookies are small files placed on your hard drive by an internet server when you visit a website. Some cookies can be used to identify your computer each time you visit a site.

Our Website uses cookies to allow authentication for access to the Subscriber Only areas of our sites. This allows you to leave the site and come back without having to re-enter your email or user name and password every time. We may also use cookies to track site usage, traffic patterns and to deliver ads for services we think will be of interest to you.

Your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our Website may not function as well as intended.

We respect your privacy choices and will honor any global privacy control signals you may send through your browser or device. If you have opted out of cookies used for targeted advertising or the sale of your personal information, you may wish to clear any existing cookies from your browser. To do so please see the below instructions:

Google Chrome

• Open DevTools:
  • Press F12 or Ctrl+Shift+I (Windows/Linux) or Command+Option+I (macOS) to open Developer Tools.
• Navigate to the Application Tab:
  • Click on the Application tab in the DevTools interface.
  • If you don’t see it, click on the More tools icon (three vertical dots) and select Application.
• Access Cookies:
  • In the left sidebar, expand the Storage section.
  • Click on Cookies, then select the website (origin) for which you want to delete cookies.
• Delete Cookies:
  • To delete a specific cookie, select it from the list and click on the Delete selected button in the top action bar.

Microsoft Edge

• Open DevTools:
  • Press F12 or Ctrl+Shift+I (Windows) to open Developer Tools.
• Go to the Application Tab:
  • Select the Application tab from the DevTools menu.
  • If it’s not visible, click on the More tools icon and then choose Application.
• Locate Cookies:
  • In the left sidebar, expand the Storage section.
  • Click on Cookies, then choose the relevant origin.
• Remove Cookies:
  • To delete a specific cookie, select it and click on the Delete selected option in the action bar.

Safari

• Enable Developer Tools:
  • Open Safari.
  • Go to Safari in the top menu and select Preferences.
  • Navigate to the Advanced tab.
  • Check the box that says Show Develop menu in menu bar.
• Open Developer Tools:
  • Right-click on the webpage and select Inspect Element or press Command+Option+I to open the Developer Tools.
• Navigate to Storage:
  • Click on the Storage tab in the Developer Tools.
  • Expand the Cookies section in the left sidebar to see a list of websites.
• Delete Cookies:
  • Select the website for which you want to delete cookies.
  • Right-click on individual cookies and select Delete, or click on the Clear All button to remove all cookies for that site.

Firefox

• Open Developer Tools:
  • Press F12 or Ctrl+Shift+I (Windows/Linux) or Command+Option+I (macOS) to open Developer Tools.
• Access Storage Inspector:
  • Click on the Storage tab within Developer Tools.
  • In the left sidebar, expand the Cookies section to view cookies for each domain.
• Delete Cookies:
  • Select a specific website under Cookies.
  • Right-click on an individual cookie and choose Delete Cookie.
  • To delete multiple cookies, you can select them while holding down the Ctrl (or Command) key and then right-click to delete.

Important Note:

When clearing cookies, be careful not to delete any cookies that store your preferences. These are labelled “OptanonConsent” and “OptanonAlertBoxClosed”.

Our Website may include hyperlinks to other websites or Apps that are not operated or controlled by us. This privacy policy only applies to our Website and Apps and we are not responsible for the content or the privacy practices of third-party websites. You should review the privacy notices of other websites that you use to learn about their data practices.

The Website may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Website, these companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public. Your interactions with third-party companies and your use of their features are governed by the privacy notices of the companies that provide those features. We encourage you to carefully read the privacy notices of any accounts you create and use.

We require that all third party e-mails promoting greyswanfraternity.com or our products are sent only to those who have agreed to receive such messages. We prohibit any advertising of us and our websites using unsolicited email messages. We will terminate our relationship with any third parties who do not comply with this policy.

If you feel you’ve been sent unsolicited emails promoting us or our websites and would like to register a complaint, please click here. We will immediately investigate your complaint.

If at any time you wish to be removed from any of the Sovereign Offshore Services, LLC mailing lists, please click here to contact our customer service department.

We fund our free daily editorial emails, Grey Swan Investment Fraternity by advertising our services and those of other group companies (occasionally we may carry advertising for a third-party service) within our editorial email, and by sending separate promotional emails. There is an unsubscribe link in each of these emails and you can unsubscribe at any time.

We may update this privacy policy from time to time in response to changing legal, technical or business developments. When we update our privacy policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material privacy policy changes if and where this is required by applicable data protection laws. You can see when this privacy policy was last updated by checking the “last updated” date displayed at the top of this privacy policy.

If you have any questions or concerns about our use of your personal information, please contact our Customer Service Team.

Address:
Sovereign Offshore Services, LLC
1001 Cathedral Street
Baltimore, MD 21202 US

Toll-free 1-800-370-0947
International 1-443-353-4212

This section contains disclosures required by the California Consumer Privacy Act (“CCPA”), the California Privacy Rights Act (“CPRA”), the Consumer Data Protection Act (“CDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Consumer Privacy Act (UCPA), the Oregon Consumer Privacy Act (OCPA), the Texas Data Privacy and Security Act (TDPSA) and the Montana Consumer Data Privacy Act (MTCDPA)), the Iowa Consumer Data Protection Act (ICDPA), the Delaware Personal Data Privacy Act (DPDPA), the Nebraska Data Privacy Act (NDPA), the New Hampshire Privacy Act (NHPA) and the New Jersey Data Privacy Act (NJPA), and applies only to “personal information” that is subject to the CCPA/CPRA, CDPA, CPA, CTDPA, UCPA, OCPA, TDPSA, MTCDPA, ICDPA, DPDPA, NDPA, NHPA and NJPA. Consumers with disabilities may access this notice by contacting our customer service team at 1-800-370-0947.

We collect the categories of personal information about California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Iowa, Delaware, Nebraska, New Hampshire and New Jersey consumers identified in the chart below.   In the past 12 months we have disclosed and sold/shared California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Iowa, Delaware, Nebraska, New Hampshire and New Jersey consumers’ personal information to third parties for business or commercial purposes – details are set out in the chart below. We do not sell/share any data collected for SMS programs.

We collect this personal information from the following categories of sources:

• Consumers
• Service providers
• Affiliates in our group companies
• Consumer data resellers

We use and disclose the personal information we collect for our commercial and business purposes as set out in this privacy policy. These commercial and business purposes include, without limitation:

• Our commercial purposes, including marketing, advertising, and enabling commercial transactions.
• Our business purposes as identified in the CCPA/CPRA, CDPA, CPA, CTDPA, UCPA, OCPA, TDPSA, MTCDPA, ICDPA, DPDPA, NDPA, NHPA and NJPA which include::
  • Auditing related to our interactions with you
  • Legal compliance
  • Detecting and protecting against security incidents, fraud, and illegal activity
  • Debugging
  • Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics
  • Internal research for technological improvement
  • Internal operations
  • Activities to maintain and improve our services
  • Effectuate a product recall
  • Comply with federal, state or local laws, rules or regulations
  • Comply with civil, criminal or regulatory inquiry, investigation, subpoena, or summons by federal, state, local, or other government authorities
  • Cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believes may violate federal, state, or local laws, rules or regulations
  • Other one-time uses

We sell the categories of personal information listed above to the categories of third parties listed below:

• Service providers
• Affiliates in our group companies
• Consumer data resellers

We disclose the categories of personal information listed above to the categories of third parties listed below for business purposes:

California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Iowa, Delaware, Nebraska, New Hampshire and New Jersey residents have certain rights with respect to the personal information collected by businesses.  If you are a California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Iowa, Delaware, Nebraska, New Hampshire or New Jersey resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

• The right to know/access the categories and specific pieces of personal information we collect, use, disclose, and sell/share about you; the categories of sources from which we collected your personal information; our purposes for collecting or selling/sharing your personal information; the categories of your personal information that we have either sold/shared or disclosed for a business purpose; and the categories of third parties with which we have shared personal information.
• The right to request that we delete the personal information we have collected from you or maintain about you. Upon verification of your request, we will notify third parties to whom we have shared your personal information with to delete your information as well.
• The right to opt out of our sale or sharing of your personal information. If you enable a global privacy control signal, we will recognize and process your request accordingly.
• The right to correct inaccurate personal information we have collected from you or maintain about you (California, Virginia, Colorado, Connecticut, Oregon, Texas, Montana, Iowa, Delaware, Nebraska, New Hampshire and New Jersey consumers only).
• The right to limit the use and disclosure of sensitive personal information we have collected from you or maintain about you, if we use this information for any purpose other than the designated purpose you agreed to (California consumers only).
• The right to opt out of targeted advertising (Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Iowa, Delaware, Nebraska, New Hampshire and New Jersey consumers only). If you enable a global privacy control signal, we will recognize and process your request accordingly.
• The right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you (Virginia, Colorado, Connecticut, Oregon, Texas, Montana, Iowa, Delaware, Nebraska, New Hampshire and New Jersey consumers only).
• The right to appeal should we be unable to act on your Privacy Request.
• The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA/CPRA, CDPA, CPA, CTDPA, UCPA, OCPA, TDPSA, MTCDPA, ICDPA, DPDPA, NDPA, NHPA and NJPA.

To exercise any of the above rights, please contact us as follows:

• By phone at 1-800-370-0947
• On our website by clicking on the “Do Not Sell My Info” link or by clicking  here

California’s “Shine the Light” law allows California residents to ask us one time each year if we have shared personal information with third parties for their direct marketing purpose. To make such a request, please contact our Customer Service Team or write to us at: Sovereign Offshore Services, LLC, 1001 Cathedral Street
Baltimore, MD 21202 US.

Under Nevada law, Nevada residents may submit a request directing us not to make certain disclosures of personal information we maintain about them.

To exercise this right, please contact us:

• Online  Privacy Web Form

We store your personal information, including sensitive personal information for different time periods depending on the category of personal information. We determine how long we need personal information on a case-by-case basis, but our goal is to keep your personal information for as short a period as possible to achieve the purpose for which personal information is collected. We consider the following criteria when we are making decisions on how long we will retain your personal information;

• The category of personal information;
• Whether the personal information is to be deleted based on a specific schedule;
• The personal information is necessary to operate or provide a service to you;
• How long we need to retain the personal information to comply with our legal and tax obligations;
• Our legitimate interests or legal purposes, such as fraud prevention, record-keeping requirements or enforcing our legal rights.

We may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. At a minimum you will need to provide your name and email address.

You may designate an authorized agent to make a CCPA request on your behalf by informing our customer service team at 1-800-370-0947. You will need to provide your name and address, your agent’s name and address, and a copy of the document by which you appointed the agent.

We do not knowingly sell the personal information of minors under 16 years of age.

If you have issues accessing or reading anything provided by Sovereign Offshore Services, LLC, please reach out to us at 1-800-370-0947 or please click here.

The Children’s Online Privacy Protection Act imposes requirements on operators of websites or online services directed to children, and on operators of websites or online services that have actual knowledge that they are collecting Personal Information about children under 13 years of age. Our currently policy is not to collect, use, sell or share any Personal Information of any person under 13 years old. If this policy changes, we will revise this portion of our Notice of Privacy Practices and will comply with the requirements of the Children’s Online Privacy Protection Act.

Primarily personal information is collected, maintained and processed in the United States. The United States may not have laws deemed adequate by the jurisdictions in which you reside. By visiting our website and/or using our App, you acknowledge and unambiguously agree to such practices pertaining to the collection, maintenance and processing of your personal information.

If you have any questions or concerns about our use of your personal information, please contact our Customer Service team.

Address:
The Grey Swan
1001 Cathedral Street
Baltimore, MD 21202
United States of America

Toll-free 1-800-370-0947
International +1-443-353-4212